Laurel Ann Curtis - Page 7




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          each parcel of real estate of which respondent was aware.  She              
          added:  “If you require additional information, please let me               
          know.”                                                                      
          Petitioner’s Motion for Sanctions                                           
               On May 16, 1996, we filed petitioner’s motion for sanctions            
          against respondent for failure to litigate in good faith (the               
          motion for sanctions), which we denied.  Exhibit H accompanying             
          the motion for sanctions purports to be a transcript (the                   
          transcript) of a meeting held on April 24, 1996, among                      
          petitioner, one of respondent’s agents, and another individual.             
          In the transcript, petitioner acknowledges receiving from                   
          respondent a breakdown of figures by property.  She also appears            
          to acknowledge that respondent’s agents had contacted her former            
          tenants to determine rents paid to her:  “Well, they were willing           
          to contact former tenants, but they weren’t willing to call, for            
          example, the Multnomah County Tax Assessor.  * * *  I mean they             
          really didn’t endeavor to find anything that wasn’t detrimental             
          to me.”                                                                     
          Petitioner’s Discovery                                                      
               Petitioner attempted both informal and formal discovery and            
          requested admissions from respondent (without distinction,                  
          petitioner’s discovery requests).  With few exceptions,                     
          petitioner’s discovery requests did not seek information about or           
          concerning the adjustments made by respondent in the notices of             






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